Record of Communication

Subject:  Logistics for Cylinder Analysis

On December 7, 2009, Lyn Gameson of the National Institute of Standards
and Technology (NIST) responded to an inquiry from John Schakenbach of
the Environmental Protection Agency (EPA) regarding Protocol Gas
Verification Program (PGVP) logistics that would allow accurate, low
cost, and fast cylinder analysis.

EPA Assumptions:

a.)  We believe there are approximately 14 specialty gas companies that
market EPA Protocol gases; some of these companies have multiple
production sites.  We estimate there are about 30 EPA Protocol gas
production sites in the U.S.

b.)  Each of these production sites would enter into an agreement with
NIST each year to analyze cylinders and produce and send to EPA reports
and to determine whether the certification label accompanying each
cylinder meets the requirements of the Traceability Protocol for up to 4

cylinders from each production site, for a total of 120 cylinders.

c.)  Therefore, in less than one year, each year, NIST would need to
analyze and produce and send to EPA reports for up to 120 cylinders, and
determine whether the certification label accompanying each cylinder
meets the requirements of the Traceability Protocol.

d.)  EPA (through our contractor) would send NIST 6 batches of 20
cylinders each.  Each batch would have cylinders of similar composition
and concentration.

EPA Questions:

-  Is 20 cylinders per batch optimum for you?

-  How long should we wait between batch shipments?

-  Assuming the appropriate interval between batches, how long would it
take NIST to complete all of the tasks in b.) above for all 120
cylinders?

-  Can cylinder batches arrive at NIST and can analysis start at any
time during the year?

NIST Assumptions:

a)	All audit cylinders will be purchased by the contractor and stored by
them.

b)	We will be sent a list of the cylinders purchased, including copies
of the vendor Certificates of Analysis.

c)	We will inform the contractor what cylinders to ship and when - most
probably in batches of 20 cylinders of the same range.

d)	The audit gas mixtures will be in three ranges, currently:

		High: CO2 at 20%; NO at 900 ppm; SO2 at 1000 ppm

		Mid: CO2 at 12%; NO at 400 ppm; SO2 at 500 ppm

		Low: CO2 at 5%; NO at 50 ppm; SO2 at 50 ppm

e)	We understand that the gas mixture compositions may change in the
future.  If the following hold true for future changes, then there will
be little or no impact on our schedule:

		 e1)	No more than three gas mixture ranges

		 e2)	The concentration for each component falls under the following
ranges:

		 	CO: 2 - 20%

		 	NO: 50 - 1000 ppm

		 	SO2: 50 - 1000 ppm

If future changes fall outside these assumptions, then we need to be
informed as soon as possible so that we can discuss the impact on our
schedule (and costs).

f)	No impurity (including NOx) analysis is required.

NIST Answers:

If the above assumptions hold, then the answers are:

Question:  Is 20 cylinders per batch optimum for you?

Answer:  Yes.

Question:  How long should we wait between batch shipments?

Answer:  As per our instructions / schedule. Typically, two weeks.

Question:  Assuming the appropriate interval between batches, how long
would it take NIST to complete all of the tasks in b.) above for all 120
cylinders?

Answer:  Six months (including report write up) - maximum.

Question:  Can cylinder batches arrive at NIST and can analysis start at
any time during the year?

Answer:  As per our instructions / schedule. We are planning to be in
position to take delivery of the first batch in early February.

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